COMMONWEALTH OF THE NORTHERN MARIANA ISLANDS, GOVERNOR OF THE
NORTHERN MARIANA ISLANDS, COMMISSIONER OF THE DEPARTMENT OF PUBLIC SAFETY,
SECRETARY OF THE DEPARTMENT OF LABOR AND IMMIGRATION, SECRETARY OF
THE DEPARTMENT OF COMMUNITY AND CULTURAL AFFAIRS,

Defendants.

COMPLAINT

THE UNITED STATES OF AMERICA alleges:

1. The Attorney General files this complaint on behalf of the United
States of America pursuant to the Civil Rights of Institutionalized
Persons Act of 1980, 42 U.S.C. § 1997, and 42 U.S.C. § 14141,
to enjoin the named Defendants from depriving persons incarcerated in the
Commonwealth of the Northern Mariana Islands ("CNMI") at the Saipan Prison
Complex ("SPC"), the Saipan Detention Facility ("SDF"), the Kagman Youth
Facility on Saipan ("KYF"), the Saipan Immigration Detention Facility ("SIDF"),
the Tinian Detention Facility ("TDF"), and the Rota Detention Facility
("RDF"), of rights, privileges, or immunities secured and protected by
the Constitution of the United States.

JURISDICTION AND VENUE

2. This Court has jurisdiction over this action under 28 U.S.C. §§
1331 and 1345, and 48 U.S.C. § 1822(a).

3. The United States is authorized to initiate this action pursuant
to 42 U.S.C. § 1997a, and 42 U.S.C. § 14141(b), applicable to
the CNMI through Section 105 of the Covenant to Establish a Commonwealth
of the Northern Mariana Islands in Political Union with the United States
of America (1978).

4. The Attorney General has certified that all pre-filing requirements
specified in 42 U.S.C. § 1997b have been met. The Certificate of the
Attorney General is appended to this Complaint and is incorporated herein.

5. Venue is proper in the District of the Northern Mariana Islands pursuant
to 28 U.S.C. § 1391.

7. The Governor of the CNMI is sued in his official capacity as the
CNMI official ultimately responsible for the operations of SPC, SDF, KYF,
SIDF, RDF, and TDF.

8. The Commissioner of the Department of Public Safety is sued in his
official capacity as the official in charge of supervising the operations
of SPC, SDF, RDF, and TDF.

9. The Secretary of the Department of Labor and Immigration is sued
in his official capacity as the official supervising the operations of
SIDF.

10. The Secretary of the Department of Community and Cultural Affairs
is sued in her official capacity as the official supervising the operations
of KYF.

11. Defendants are legally responsible, in whole or in part, for the
operation of SPC, SDF, KYF, SIDF, RDF, and TDF, and for the conditions
in these facilities and the health and safety of persons confined, detained,
or incarcerated in them.

12. At all relevant times, the Defendants or their predecessors in office
have acted or failed to act, as alleged herein, under color of state law.

20. The CNMI officers staffing SPC, SDF, SIDF, RDF, and TDF are law
enforcement officers. The CNMI staff at KYDF are responsible for the administration
of juvenile justice and the incarceration of juveniles.

22. Defendants have been aware of the factual allegations set forth
in paragraph 21 for a substantial period of time and have failed to address
adequately the conditions described although they consciously knew of those
inadequacies.

VIOLATIONS ALLEGED

23. The acts and omissions alleged in paragraphs 21 and 22 violate the
rights, privileges, or immunities secured or protected by the Constitution
of the United States of persons confined in SPC, SDF, KYF, SIDF, RDF, and
TDF.

24. Unless restrained by this Court, Defendants will continue to engage
in the conduct and practices set forth in paragraphs 21 and 22 that deprive
persons confined in SPC, SDF, KYF, SIDF, RDF, and TDF of their rights,
privileges, or immunities secured or protected by the Constitution of the
United States and cause them irreparable harm.

PRAYER FOR RELIEF

25. The Attorney General is authorized under 42 U.S.C. § 1997 etseq. and 42 U.S.C. § 14141(b) to seek equitable and declaratory
relief.

WHEREFORE, the United States prays that this Court enter an order permanently
enjoining Defendants, their officers, agents, employees, subordinates,
successors in office, and all those acting in concert or participation
with them from continuing the acts, omissions, and practices set forth
in paragraph 21 above, and that this Court require Defendants to take such
actions as will ensure constitutional conditions of confinement are afforded
to inmates at SPC, SDF, KYF, SIDF, RDF, and TDF.

The United States further prays that this Court grant such other and
further equitable relief as it may deem just and proper.

Respectfully submitted,

___________________________
JANET RENO
Attorney General of the
United States